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May 18, 1999

CLA-2-05:RR:NC:2:231 E81169


TARIFF NO.: 0511.99.2000

Mr. Craig Schau
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, OH 44130

RE: The tariff classification of rawhide dog chews from Argentina.

Dear Mr. Schau:

In your letter, dated April 22, 1999, you have requested a tariff classification ruling on behalf of your client, New England Enterprise, Manchester, CT. You also inquire as to country of origin marking.

The submitted sample is a rawhide dog chew. During the manufacturing process (which takes four days), strips of cowhide are shaped into bones and then placed into ovens for drying. The product is designed as a chew for dogs.

The applicable subheading for rawhide dogs chews will be 0511.99.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for animal products not elsewhere specified or included; dead animals of chapter 1 or 3, unfit for human consumption, other, other, parings and similar waste of raw hides or skins; glue stock not elsewhere specified or included. The rate of duty will be free.

With regard to the question of country of origin marking, Section 134.11, Customs Regulations, states that "Unless excepted by law, Section 304, Tariff Act of 1930, as amended (19 USC 1304) as hereinafter provided, requires that every article of foreign origin (or its container) imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or container) will permit in such manner as to indicate to an ultimate purchaser in the United States the English name of he country of origin of the article, at the time of importation into the Customs territory of the United States. Containers of articles excepted from marking shall be marked with the name of the country of origin of the articles unless the container is also excepted from marking."

The instant hide chews are manufactured from rawhide. During processing, rawhide is split, with the outer layer generally being further processed into leather; the inner or corium layer is used as a raw material for dog chews, glue stock, or other uses. The finished articles, dog chews, are capable of being marked, either themselves or their retail containers, headers, etc. They are not described in Section 134.32, CR, "General exceptions to marking requirements," nor would they be considered rawhide, unfinished leather or other products included in the "J-List exceptions" listed in section 134.33, CR. Further, Headquarters ruling of January 27, 1997, file number HQ 560161, required country of origin marking for similar rawhide dog chews. Accordingly, since these chews are capable of being marked with country of origin, and since they are not excepted from the marking requirement in section 134.11, CR, by any provision in subpart D, "Exception to Marking Requirements," marking with country of origin will be required for these goods.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Thomas Brady at (212) 637-7064.


Robert B. Swierupski

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